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Today’s 911 system is built on an infrastructure of analog technology that does not support many
of the features that most Americans expect are part of an emergency response. Efforts to splice
newer, digital technologies onto this aging infrastructure have created points of failure where a
call can be dropped or misdirected, sometimes with tragic consequences. Callers to 911, however,
generally assume that the newer technologies they are using to place a call are matched by the
same level of technology at the 911 call center. This is not the case. For example, except for some
work-around solutions, Public Safety Answering Points (PSAPs)—the call centers—cannot
receive text messages. Delays in moving calls from digital to analog mode add life-threatening
seconds to the completion of a 911 call. Information about a caller’s location may not be accurate,
especially in the case of wireless calls. Technology to supply accurate location information for
wireless calls is useless unless the systems receiving and processing the call have matching
capability. Modernizing the system to provide the quality of service that approaches the
expectations of its users will require investments in new technologies. The general consensus is
that these new technologies, collectively referred to as Next Generation 911 or NG9-1-1, should
incorporate Internet Protocol (IP) standards. An IP-based emergency communications network
that supports 911 will facilitate interoperability and system resilience; improve connections
between 911 call centers,provide more robust capacity; and offer flexibility in receiving calls.
Recognizing the importance of providing effective 911 service, Congress has passed three major
bills supporting improvements in the handling of 911 emergency calls. The most recent of
these—the NET 911 Improvement Act of 2008 (P.L. 110-283)—requires the preparation of a
National Plan for migrating to an IP-enabled emergency network. The plan is to be prepared by
the E-911 Implementation Coordination Office (ICO), created to meet requirements of an earlier
law, the ENHANCE 911 Act of 2004 (P.L. 108-494). ICO is co-administered by the National
Telecommunications and Information Administration and the National Highway Traffic Safety
Administration of the U.S. Department of Transportation (DOT).
The ICO is scheduled to terminate on October 1, 2009. Although Congress has required that the
National Plan be completed in April 2009, this leaves little time to implement recommendations;
other goals set for the ICO by Congress will likely not be met. The National Plan could guide
policies to strengthen the nation’s 911 system, if there is an agency or organization to provide the
needed leadership to implement the plan’s recommendations and other policy decisions. To assure
continuity of leadership, Congress may choose to re-authorize the ICO. It could also consider
other means to coordinate Congressional policy and monitor progress toward the fundamental
policy goal of creating an IP-enabled emergency communications network.
Other types of citizen-activated emergency calls are handled in call centers. Increasingly many
calls for assistance are placed by dialing 211. The number has been provisionally designated for
community information and referrals. Service levels and response times for 211 calls would
benefit from a transition to IP-enabled networks and in many cases could share infrastructure with
911 networks. Legislation introduced in 111th Congress includes two bills covering 211 call
centers: S. 211 (Senator Clinton) and H.R. 211 (Representative Eshoo).

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Next Generation 911........................................................................................................................ 1
Congressional Policy for NG9-1-1............................................................................................ 4
Summary of 911 Legislation and Policy ......................................................................................... 5
The 911 Act and Federal Communications Commission Regulations ...................................... 6
FCC Study: The Hatfield Report......................................................................................... 6
The ENHANCE 911 Act of 2004.............................................................................................. 7
The NET 911 Improvement Act of 2008................................................................................... 8
Building Policy and Creating the Base for Change......................................................................... 9
Equality of Service and Access to 911 ...................................................................................... 9
Mechanisms to Improve Funding for PSAPs and Monitor Collections and
Disbursements........................................................................................................................ 9
Federal Leadership in Improving 911 Capabilities ................................................................. 10
Transition to IP-Enabled 911 Systems .....................................................................................11
Effecting Change ............................................................................................................................11
New Technologies ....................................................................................................................11
NG9-1-1: Department of Transportation Programs .......................................................... 12
NG9-1-1: Goals and Features ........................................................................................... 12
Pilot Program .................................................................................................................... 13
Next Step........................................................................................................................... 13
Investment in Infrastructure .................................................................................................... 13
Devices.............................................................................................................................. 14
Local Networks................................................................................................................. 14
Call Centers....................................................................................................................... 14
Interfaces with First Responders....................................................................................... 14
Investment in NG9-1-1 ........................................................................................................... 15
Federal Grants ......................................................................................................................... 15
The Potential Role of the Department of Homeland Security................................................. 16
National Emergency Communications Plan ..................................................................... 16
Congress and the Emergency Communications Safety Net .................................................... 17
Benefits of Re-Authorizing the E-911 Implementation Coordination Office ......................... 17
Primary Policy Goal.......................................................................................................... 18
Supporting Policy Goal: Organization.............................................................................. 18
Supporting Policy Goal: Infrastructure ............................................................................. 19

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Appendix A. 911 Legislation and Policy....................................................................................... 20
Appendix B. Citizen-Activated Calls: 211 .................................................................................... 29

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Author Contact Information .......................................................................................................... 31

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he underlying systems for 911 calls today operate almost exclusively on analog
technology, using an architecture of circuits and switches developed when the American
T Telephone & Telegraph Company was a regulated monopoly providing most of the
nation’s telephone service.1 Modern communications innovations such as digitization, packet
switching, and Internet Protocol (IP) standards are alien concepts in an outdated system design
that “literally chokes off the use of all but the most rudimentary features of modern end-user
devices and stifles the development of more specialized equipment and services.”2 Systems for
911, unable to accommodate the latest advances in telecommunications technology, are
increasingly out-dated, costly to maintain, and in danger of failure.3
Consumer expectations for accurate and timely response to 911 calls are based on the advanced
features available on most communications devices, not on the reality of a faltering legacy
system. The analog system cannot carry text messages, for example. Calls are delayed or dropped
when analog and digital systems do not mesh. Information on the location of the call is lost
because the digital details cannot be transmitted by the underlying telecommunications
infrastructure or understood by the computers at Public Safety Answering Points (PSAPs). PSAPs
are the call centers that receive and relay 911 calls. As summarized in a National Emergency
Number Association (NENA) report, “Simply put, the 9-1-1 system has not kept up with
technology and is badly in need of modernization.”4 Modernizing the system to provide the
quality of service that approaches the expectations of its users will require investments in new
technologies. The general consensus is that present and future digital communications would be
best supported by Next Generation 911 technology (NG9-1-1). The term NG9-1-1 is widely used
to refer to the modernization of all parts of the 911 system, including hardware, software, data,
and operational policies and procedures, all supported by multi-purpose emergency service
networks.
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The emergency communications network of the future is envisioned as IP-based, using
standardized protocols, and providing a nationwide overlay of system links that can operate at the
national, regional, tribal, state, or local level to best meet the needs of specific circumstances.
Such a network, if fully realized, could support many types of emergency communications needs,
including first responder networks and emergency alerts. A network overlay for 911 systems can,
for example, facilitate interoperability and system resilience by bringing extra resources to
devastated areas where 911 call centers are damaged or overwhelmed with calls. On a daily basis,
it can provide foreign language assistance at any time, anywhere.5 Other benefits include better

1 Dale Hatfield, Brad Bernthal, and Phil Weiser, Health of the US 9-1-1 System, sponsored by the 9-1-1 Industry
Alliance, 2008, Part II, “Section B. Background and Evolution of Our Nation’s 9-1-1 System,” page 20. Report at
http://www.911alliance.org/9IA_Health_of_US_911%20_2_.pdf.
2 Ibid., page 19.
3 Ibid. Part II, “Section D. Constraints and Shortcomings Associated with the Current 9-1-1 System.” See also, “An
SOS for 9-1-1 Systems in Age of High-Tech,” by Shaila Dewan, The New York Times, April 6, 2007.
4 NENA, Next Generation Partner Program, A Policy Maker Blueprint for Transitioning to the Next Generation 9-1-1
System: Issues and Recommendations for State and Federal Policy Makers to Enable NG9-1-1, page 2. Report at
http://www.nena.org/media/File/NG9-1-1PolicyMakerBlueprintTransitionGuide-Final_1.pdf.
5 For example, the Washington Post reported that in 2007, in Fairfax County, VA, 911 calls were translated into 66
different languages. “Cellphones Drive Jump in 911 Use; Workloads and Costs Soar with Increased Calls and
Translation Needs,” by Amy Gardner, October 26, 2008 at http://www.washingtonpost.com/wp-dyn/content/article/
(continued...)
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connections between 911 call centers, emergency responders, and alert and warning systems;
more robust capacity; and the flexibility to receive calls for help in any format. Benefits like these
are among the reasons that Congress has required the preparation of a National Plan to prepare
911 for the transition to an IP-enabled emergency communications network.6 An IP-enabled
network for emergency communications has been defined as a “network based on an
infrastructure allowing secured transmission of data among computers that use the Internet
Protocol.”7
Implementing NG9-1-1 will require not only the development of an IP-enabled network and
systems but will also entail changes in operational procedures, training, funding models, and
state—and possibly federal—regulations and laws. The National Emergency Number Association
(NENA) began planning for the future of 911 under the banner of NG9-1-1 in 2000.8 NENA
started work on standards development for NG9-1-1 in 2003 and since then has taken the lead in
defining, designing, and developing NG9-1-1 systems and solutions in partnership with other
associations, as well as representatives from industry, government, and the public safety
community.9 Support for NG9-1-1 now comes from a broad base, including
• State and local managers for emergency communications and 911.
• Associations such as NENA, COMCARE,10 the National Association of
Regulatory Utility Commissioners (NARUC),11 the Association of Public-Safety
Communications Officials International, Inc. (APCO),12 and the National
Association of State 911 Administrators (NASNA).13 Many other international,
national, and state and local associations are also actively involved in supporting
911.14
• Alliances such as the 911 Alliance,15 the Alliance for Telecommunications
Industry Solutions (ATIS),16 the Internet Engineering Task Force (IETF),17 and
the E9-1-1 Institute—which supports the Congressional E9-1-1 Caucus.18

(...continued)
2008/10/25/AR2008102502052.html.
6P.L. 110-283, Sec. 102, (3) “(d) “(1); 122 STAT. 2623.
7 47 CFR Part 400, E-911 Grant Program, §400.2 Definitions. Federal Register, October 3, 2008; link at
http://www.ntia.doc.gov/frnotices/2008/FR_E911grants_081003.pdf.
8 NENA NG9-1-1 Project at http://www.nena.org/pages/ContentList.asp?CTID=65.
9 For example, on May 2, 2007, NENA and The Association of Public-Safety Communications Officials International,
Inc. (APCO) issued a joint statement announcing an agreement to work together in advancing the transition of 911 to
new technologies and capabilities. The two associations agreed to share information and coordinate activities. NENA
will focus on technical and architectural components of new 911 systems and APCO will focus on the operational
utility of these systems. See http://www.nena.org/media/files/NGNENA-APCOAllianceRelease.pdf.
10 COMCARE, Emergency Response Alliance at http://www.comcare.org/.
11 Information at http://www.naruc.org/about.cfm.
12 Information at http://www.apcointl.org/new/commcenter911/.
13 Information at http://www.nasna911.org/current-issues.php.
14 For example, the European Union supports the European Emergency Number Association—EENA 112, see
http://www.eena.org/.
15 At http://www.911aliance.org.
16 At http://www.atis.org/esif/.
17 At http://www.ietf.org/overview.html.
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• Corporations and other commercial organizations serving public safety and
emergency communications.19
• The Intelligent Transportation Systems (ITS) Public Safety Program and the
National Highway Traffic Safety Administration (NHTSA) within the U.S.
Department of Transportation (DOT).
Notably, NENA and DOT have partnered to encourage the deployment of NG9-1-1. Among
DOT’s contributions in support of NG9-1-1 are the funding and supervision of five proof-of-
concept pilots to test key components of NG9-1-1 in PSAPs.20 In addition to the pilots established
by DOT, at least six states and the District of Columbia are reported to have IP-based networks
for emergency communications that will support NG9-1-1 systems.21
Congress created an E-911 Implementation Coordination Office (ICO) to participate in the efforts
to improve 911 systems. The ENHANCE 911 Act of 2004 (P.L. 108-494) directed NHTSA to
serve as co-administrator with the National Telecommunications and Information Administration
(NTIA) in establishing and directing the ICO.22 The NET 911 Improvement Act of 2008 (P.L.
110-283) gave the office the further responsibility of creating the National Plan for the transition
to an IP-enabled emergency communications network.23
NENA estimates that the earliest a fully standards-compliant NG9-1-1 system could be in place
would be mid-2010.24 Two key federal programs—DOT’s NG9-1-1 proof of concept and the
ICO—are currently scheduled to end just as states and communities are beginning to deal with
the logistics and costs of replacing out-of-date systems. Congress has set an April 2009 deadline
for completion of the National Plan. This leaves little time to implement recommendations before
the ICO’s authorization expires on October 1, 2009. If ICO and DOT programs are not extended
or replaced, the only federal agency with a continuing role in implementing national policies to
improve 911 systems and services will be the Federal Communications Commission (FCC). The
FCC has so far used its powers primarily as a regulator to enforce requirements for provision of
911 connections, not as an E-911 policy-making body.

(...continued)
18 At http://www.e911institute.org/e911caucus.html; additional information at the E911 Institute web page
http://www.e911institute.org/index.html.
19 For example, members of the NENA Next Generation Partner Program as listed in A Policy Maker Blueprint for
Transitioning to the Next Generation 9-1-1 System: Issues and Recommendations for State and Federal Policy Makers
to Enable NG9-1-1, op. cit.
20 Participants that are testing the network prototype are: City of Rochester, NY—Emergency Communications
Department; Seattle, WA—King County E-911 System; St. Paul, MN—Metropolitan Emergency Services Board,
Ramsey County Emergency Communications Center; State of Montana—Public Safety Services Bureau; and State of
Indiana—Office of State Treasurer, Indiana Wireless 911 Board. Source: “US DOT Announces Partnerships For Next
Generation 9-1-1 Initiative—Proof of Concept,” e-mail announcement, Laurie Flaherty, U.S. Department of
Transportation, January 16, 2008.
21 These are Florida, Indiana, Minnesota, New Mexico, and Rhode Island. Source: NENA, Status of NG9-1-1 Related
IP Networks, Demos and Trials at http://www.nena.org/pages/Content.asp?CID=373&CTID=65. Indiana is also
participating as one of the DOT pilot projects to test the interface between state IP-networks and the national overlay
being considered in DOT’s NG9-1-1 program. According to DOT, Vermont has also established an IP backbone and
numerous regional/local networks are upgrading to an IP-based network. Source: e-mail communication from Will
Otero, Director, Legislative Affairs, National Highway Traffic Safety Administration, October 21, 2008.
22 P.L. 108-494, Sec. 104, “Sec. 158, “(a) “(2);118 STAT. 3987.
23 P.L. 110-283, Sec. 102, (3) “(d) “(1); 122 STAT. 2623.
24 Ibid.
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The implementation of IP-based NG9-1-1 embraces many complex and inter-related decisions
about, for example, governance, standards and technology, funding, and leadership. Congress has
addressed some of these issues in the context of existing 911 infrastructure and technology, and
has recognized the need to plan for the transition to the next generation. This transition will, over
time, present many new policy issues. Congressional policy goals for the future could include
• Addressing emergency communications needs and goals with a policy statement
that recognizes the convergence of technologies, especially IP-based networks
and standards, that will place first responder networks, 911 systems, and
emergency alert systems on common, interoperable platforms.
• Identifying the federal role in implementing national policies for emergency
communications without eroding state or local authority.
• Defining the role of the Department of Homeland Security, especially the
Regional Emergency Communications Coordination Working Groups that it
supports, in guiding policies to sustain and improve 911 as part of its Emergency
Communications Plan.
• Reviewing the federal regulatory role in promoting competition in the provision
of network services to PSAPs.25
• Designating radio frequency spectrum to provide connectivity to PSAPS, for
example by using wireless technologies such as microwave transmission in place
of fiber-optic cables.
• Addressing the quality of interfaces with other emergency communications
networks, especially the radio links to first responders, and their spectrum needs.
• Providing funding solutions.
• Establishing national guidelines or requirements for minimum levels of 911
service.
• Establishing a program to assure that the quality of 911 services improves
steadily, nationwide.
The balance of this report describes the development of Congressional policy in support of 911,
technology and infrastructure, federal programs, the transition to IP-enabled emergency
communications, costs, and other elements of change before returning to a discussion of goals for
the future.

25 The wireline circuits that complete the connection to the PSAPs are usually owned and operated by either an
Incumbent Local Exchange Carrier (ILEC) or a Competitive Local Exchange Carrier (CLEC), operating under different
regulatory requirements and protections. The Wireline Competition Bureau of the FCC oversees federal regulation of
ILECs and CLECs.
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This section discusses how past federal legislative and policy actions regarding 911 have
established a base for the transition to IP-enabled systems. Three major laws supporting
improvements in the handling of 911 emergency calls have been enacted since 1999. These and
other laws support policy objectives and strategies that provide the base upon which future policy
might be built. Analyzing the legislation as a continuum, these key goals emerge: equality of
service and access to 911; mechanisms to improve funding for PSAPs and monitor collections
and disbursements; federal leadership in developing better 911 capabilities; and transition to IP-
enabled 911 systems. The major bills enacted into law are
• The Wireless Communications and Public Safety Act of 1999 (P.L. 106-81), often
referred to as the 911 Act.
• The Ensuring Needed Help Arrives Near Callers Employing 911 Act of 2004
(P.L. 108-494), also titled the ENHANCE 911 Act of 2004.
• The New and Emerging Technologies 911 Improvement Act of 2008 (P.L. 110-
283), also titled the NET 911 Improvement Act of 2008.
Provisions in other recently enacted laws have also contributed to the growing base of legislation
in support of 911.
• The 21st Century Emergency Communications Act, Title VI, Subtitle D, in the
Department of Homeland Security Appropriations Act, 2007 (P.L. 109-295)
required that PSAPs be included as members of Regional Emergency
Communications Coordination Working Groups established by the act.26
• The Homeland Security Appropriations Act, 2007 (P.L. 109-295) required the
FCC to prepare a report on state, local, and tribal plans for backup service for 911
and E-911 when PSAPS are disabled.27
• The Deficit Reduction Act (P.L. 109-171),28 as amended by the Implementing
Recommendations of the 9/11 Commission Act of 2007 (P.L. 110-53)29 and the
NET 911 Improvement Act of 2008,30 provided up to $43.5 million for grants for
911.
• The Implementing Recommendations of the 9/11 Commission Act of 2007 (P.L.
110-53) included financial support of PSAPs as eligible uses for Urban Area
Security Initiative and State Homeland Security Grant programs.31
• The Food, Conservation, and Energy Act of 2008 (P.L. 110-234) included
language that authorized loans to improve 911 and other emergency
communications capabilities in rural areas.32

26 P.L. 109-295, Sec. 671 (b) “Title XVIII, “Sec. 1805, “(b) “(1) “(F); 120 STAT. 1439.
27 P.L. 109-295, Sec. 674; 120 STAT. 1444.
28 P.L. 109-171, Sec. 3011; 120 STAT. 27.
29 P.L. 110-53, Sec. 2302 and 2303; 121 STAT. 543.
30 P.L. 110-283, Sec. 102 (1); 122 STAT. 2623.
31 P.L. 110-53 Sec. 2008; 121 STAT. 283.
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To assist the effort to provide comprehensive 911 services nationwide, Congress in 1999 passed
the Wireless Communications and Public Safety Act (P.L. 106-81), often referred to as the 911
Act, that mandated 911 as the national emergency number33 and provided for parity of wireless 9-
1-1 services with the protections and authorizations already extended to wireline services.34
Among its provisions, the law required the FCC to work with the states and the many other
affected parties to deploy comprehensive wireless enhanced 911 (W-E911) service. Enhanced 911
service provides 911 call centers with Automatic Number Identification (ANI) and Automatic
Location Identification (ALI).35 Most wireline phone services provide ANI/ALI information.36
The 911 Act set the broad goal of facilitating “the prompt deployment throughout the United
States of a seamless, ubiquitous, and reliable end-to-end infrastructure for communications,
including wireless communications, to meet the Nation’s public safety and other communications
needs.”37 The FCC had taken a first step toward adopting rules for wireless enhanced 911 in 1996,
citing provisions of the Communications Act38 as the basis for its action. After Congress passed
the 911 Act, the FCC plotted a course for reaching wireless in two phases. For Phase I, the
wireless carriers were given a year to prepare for PSAP requests for Automatic Number
Identification (ANI) and location-finder capabilities using technology existing at the time. By
2001, for Phase II, the carriers were to have identified and implemented new location-finder
technologies (ALI). A 1999 FCC ruling established October, 1, 2001, as the deadline for wireless
carriers to meet guidelines for connecting 911 calls to PSAPs.39
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Delays and complications in implementing wireless prompted the FCC to commission a study to
examine deployment of 911 services in general and the cause of problems with wireless 911 calls
in particular. The report, known as the Hatfield Report, was submitted to the FCC on October 15,
2002.40 The author, Dale N. Hatfield, formerly Chief, Office of Engineering and Technology at
the FCC, was assisted in his research by staff in the FCC’s Commercial Wireless Division of the

(...continued)
32 P.L. 110-234, Sec. 6107; 122 STAT. 1198.
33 P.L. 106-81, Sec. 3. (a); 113 STAT. 1287
34 P.L. 106-81, Secs. 4 and 5; 113 STAT. 1288-89.
35 Automatic Number Identification (ANI) recognizes and displays the telephone number from which the call is placed.
Automatic Location Identification (ALI) provides—in the case of wireline—the address associated with the telephone
number or—in the case of wireless—the approximate geographic coordinates of the caller.
36 An estimated 96% of counties in the United States provide some form of 911 service, of which 93% support
enhanced 911 for wireline services. Source: National Emergency Number Association (NENA), “9-1-1 Fast Facts,” at
http://www.nena.org/pages/Content.asp?CID=144&CTID=22.
37 P.L. 106-81, Sec. 2. (b); 113 STAT. 1287.
38 U.S.C. Title 47, Chapter 5, § 151, Communications Act of 1934. The FCC’s charter includes “promoting safety of
life and property through the use of wire and radio communication.” Report and Order and Further Notice of Proposed
Rulemaking, adopted June 12, 1996 at http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-96-264A1.pdf.
39 FCC, E911 Third Report and Order, FCC 99-245, released October 6, 1999, at http://www.fcc.gov/Bureaus/
Wireless/Orders/1999/fcc99245.pdf.
40 “A Report on Technical and Operational Issues Impacting the Provision of Wireless Enhanced 911 Services” at
http://www.locatemodelcities.org/library/HatfieldReport.pdf.
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Wireless Telecommunications Bureau. The report’s focus is primarily on technical and
operational issues.41
Observations in the report that later became the basis for Congressional initiatives included
• The critical nature of location information in enhanced 911 in supporting first
responders in emergencies.
• The “seriously antiquated” condition of the infrastructure that underlies 911 for
both wireline and wireless emergency calls.
• The need for a national 911 office to act as a “champion” at the federal level.
In 2005, Mr. Hatfield began a follow-up study for the FCC on 911 topics, but it was later
discontinued by the FCC. On April 10, 2007, Mr. Hatfield testified before Congress regarding the
work he had begun for the FCC and some of the preliminary conclusions regarding needed
changes to the nation’s 911 services.42 A new version of the study was subsequently published
with support from the 9-1-1 Alliance, an industry group.43
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Congress responded to the issues raised by the 2002 Hatfield Report, by the 9/11 Commission,44
and by others, with the Ensuring Needed Help Arrives Near Callers Employing (ENHANCE) 911
Act of 2004 (P.L. 108-494). The act addressed a number of concerns that had been raised about
the deployment of 911, including compliance, coverage in rural areas, and the use of fees levied
by states and localities to help cover the cost of providing 911 services.
In response to the Hatfield Report’s call for a federal champion, the act created the E-911
Implementation Coordination Office (ICO) to, among other responsibilities, oversee a grants
program for the “implementation and operation of Phase II E-911 services.”45 Although funds
were authorized in the law, no appropriations were forthcoming until a sum was allocated by the
Deficit Reduction Act of 2005. (See further discussion in Appendix, “Mechanisms to Improve
Funding for PSAPs.”) In FY2008, DOT budgeted $1.25 million for the operation of ICO.46

41 A new report on 911, co-authored by Dale Hatfield, appeared in 2008. “Health of the US 9-1-1 System” at
http://www.911alliance.org/9IA_Health_of_US_911%20_2_.pdf.
42 Senate, Committee on Commerce, Science, and Transportation, Hearing on “Voice over Internet Protocol (VoIP) and
the Future of 9-1-1 Service,” April 10, 2007. Among other actions taken by Congress, the circumstances surrounding
the discontinuance of the study were also explored in hearings in the House of Representatives by the Committee on
Energy and Commerce, Subcommittee on Telecommunications and the Internet, “Oversight of the Federal
Communications Commission,” March 14, 2007; and by the Committee on Appropriations, Subcommittee on Financial
Services and General Government, “The Federal Communications Commission,” April 17, 2007.
43 “Health of the US 9-1-1 System” at http://www.911alliance.org/9IA_Health_of_US_911%20_2_.pdf.
44 The 9/11 Commission recommended that 911 call centers be included in planning for emergency responses. Final
Report of the National Commission on Terrorist Attacks Upon the United States, Official Government Edition, 2004, p.
318.
45 P.L. 108-498, Sec. 104, “Sec. 158, “(b) “(1); 118 STAT. 3987-3988.
46 E-mail communication from Will Otero, Director, Legislative Affairs, National Highway Traffic Safety
Administration, October 21, 2008.
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In the 110th Congress, both the House and Senate passed bills focused on ensuring access to 911
call centers for users of Voice Over Internet Protocol (VOIP) services, and improving the delivery
of 911 services nationwide. These bills became the New and Emerging Technologies (NET) 911
Improvement Act of 2008 (P.L. 110-283). The key provisions of the law are
• Duty to provide 911 and E-911 as established in the 1999 law extended to include
IP-enabled voice services in accordance with existing FCC regulations at the
time of passage of the act or as modified in the future.47
• Parity of access to communications networks needed to complete 911 calls.48
• Parity of protection from liability—provided for wireline and wireless carriers—
extended to include communications through VOIP providers and other
emergency service providers.49
• National plan for migration to an IP-enabled 911 network, developed by the E-
911 Implementation Coordination Office.50
• Protection of the rights of states and other political subdivisions to levy fees on
911 services.51
• Requirement that FCC report annually on collection of state fees and other levies
on 911 and E-911 services.52
Prior to the passage of the 911 Act in 1999, the FCC had already established regulations for the
new category of service providers—wireless carriers. Similarly, the FCC had established
requirements for VOIP—another new category of service provider—in advance of the passage of
the NET 911 Improvement Act of 2008.53 The act confirmed the FCC’s authority to require VOIP
service providers to comply with 911 connectivity requirements established for wireline and
wireless voice and to include VOIP calls in its regulatory and oversight activities for 911. In
accordance with requirements to issue regulations covering parity of access and related technical
needs and capabilities for VOIP calls, the FCC issued a Report and Order on October 21, 2008.54

47 P.L. 110-283, Sec. 101, “Sec. 6 “(a); 122 STAT. 2620.
48 P.L. 110-283, Sec. 101, “Sec. 6 “(b); 122 STAT. 2620.
49 P.L. 110-283, Sec. 201; 122 STAT. 2624.
50 P.L. 110-283, Sec. 102; 122 STAT. 2623.
51 P.L. 110-283, Sec. 101, “Sec. 6, “(f) “(1); 122 STAT. 2621.
52 P.L. 110-283, Sec. 101, “Sec. 6, “(f) “(2); 122 STAT. 2622.
53 Notably, VOIP providers must: deliver all calls to a local 911 center; provide ANI/ALI information if the call center
can receive it; and inform customers of limitations in VOIP service for delivering calls to 911. The FCC has a website
with information about VOIP, E-911, and past FCC actions at http://www.voip911.gov/.
54 FCC, Report and Order, WC Docket No. 08-171, released October 21, 2008. A detailed discussion of the FCC’s
interpretation of the act’s requirements is provided in the Report and Order at http://hraunfoss.fcc.gov/edocs_public/
attachmatch/FCC-08-249A1.pdf.
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The National Plan for the transition to IP-enabled emergency communications is expected to
recommend specific legislative language, if necessary, for realizing the plan.55 To capture the
benefit of federal efforts and to consolidate its legislative gains in the support of 911, Congress
may decide to act on the National Plan’s recommendations or may implement their own measures
in support of 911. This report identifies four policy objectives and strategies supported in the past
by Congress, and by others, as the base upon which future policy might be built. These objectives
could be addressed in the plan or may be addressed separately by Congress. The policies are
• Equality of service and access to 911.
• Mechanisms to improve funding for PSAPs and monitor collections and
disbursements.
• Federal leadership in developing better 911 capabilities.
• Transition to IP-enabled 911 systems.
These policies are summarized below. More detailed discussions and documentation are provided
in Appendix A.
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Through the laws that it has enacted, Congress has established the principle that 911 calls should
provide the same level of information and responsiveness no matter what the communications
device, or the location of the call, or the physical abilities of the caller. Congressional actions and
FCC regulations have sought to expand the capacity of the existing 911 infrastructure to
accommodate more types of devices, to improve caller location information, to provide wireless
support in more areas—with more precision—and to accommodate persons with disabilities.
In the case of 911 service, the twin policy goals of quality and equality may have bumped against
the limits of the technologies currently in place. Significant new gains in accessibility and level of
service appear to depend on implementing new technologies that are not supported by the current
network architecture. Any new legislation intended to improve 911 service may need to address
the substantial investments required to provide these improvements, including, for example,
financial assistance in acquiring the needed technology.
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Although Congress has established a federal program for grants and made 911 projects eligible
for rural area loans, the bulk of funding for 911 services comes from states and municipalities and
much of this is provided by fees assessed on telephone subscribers (including wireless and
VOIP). Congress therefore has enacted several measures designed to oversee the use of fees and
assure that they are applied for 911 or enhanced 911, as intended. For example, the program for

55 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(F) and “(G); 122 STAT. 2623.
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911 grants, under the direction of the E-911 Implementation Coordination Office, was structured
to serve as both carrot and stick, with grants for improvements denied to those who have diverted
funds collected for 911. The NET 911 Improvement Act of 2008 provided for federal monitoring
of the collection and disbursement of fees by requiring the FCC to report annually on state fees
and other levies on 911 and E-911 services.56
NENA has advocated a greater role for federal grants programs to fund both existing and next
generation 911 systems.57 Through grant programs, the federal government can both encourage
and guide the funding of 911 system improvements without diminishing state or local decision-
making and authority.
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The 911 Act and the ENHANCE 911 Act of 2004 established a baseline for Congressional
expectations of federal agencies to support 911 services. The findings of the ENHANCE 911 Act
of 2004, for example, stated
Enhanced 911 is a high national priority, and it requires Federal leadership, working in
cooperation with state and local governments and with the numerous organizations dedicated
to delivering emergency communications services.58
The 911 Act set voluntary goals for the FCC to assist states in improving 911 services.59 The
ENHANCE 911 Act of 2004 required the creation of the E-911 Implementation Coordination
Office (ICO) “to coordinate 911 services and E-911 services, at the Federal, State, and local
levels.”60 The NET 911 Improvement Act of 2008 gave the office the new responsibility of
creating the National Plan.61 These requirements provided an opportunity for the federal
government to take a leadership role by emphasizing the need for federal agencies to work
closely with state authorities to coordinate planning, information-sharing, and other steps. A chief
concern expressed by emergency communications managers and others is the need for greater
coordination of planning for NG9-1-1 among the states, to maximize benefits such as
interoperability, system resilience through shared resources, and economies of scale.
Requirements embedded in grants programs can be a tool for guiding the actions of grant
recipients and therefore provide a form of leadership. In creating the ICO, Congress intended that
it provide guidance both through the 911 grants program and by taking actions, for example, to
facilitate coordination and communication about improving 911. Congress may wish to take up
the question of a continuing federal role in support of 911 services and the possibility of using the
ICO as the main instrument for formulating and directing policy.

56 P.L. 110-283, Sec. 101, “Sec. 6, “(f) “(2); 122 STAT. 2622.
57 “NENA Applauds Presidential Signing of the New and Emerging Technologies 911 Improvement Act of 2008,”
press release, July 23, 2008 at http://www.nena.org/pages/News.asp?CID=530&TID=2.
58 P.L. 108-494, Sec. 102 (4) 118 STAT. 3986.
59 P.L. 106-81, Sec. 3 (b); 113 STAT. 3.
60 P.L. 108-494, Sec. 103, (1); 118 STAT. 3986.
61 House of Representatives, Committee on Energy and Commerce, Subcommittee on Telecommunications and the
Internet, Hearing on “Oversight of the National Telecommunications and Information Administration and Innovations
in Interoperability,” March 22, 2007, Testimony of John M.R. Kneuer, Assistant Secretary for Communications and
Information, NTIA.
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The NET 911 Improvement Act of 2008 has required the ICO to “develop and report to Congress
on a national plan for migrating to a national IP-enabled emergency network capable of receiving
and responding to all citizen-activated emergency communications and improving information-
sharing among all emergency response entities.”62 The plan is to be delivered no more than 270
days after enactment of the bill,63 a late-April 2009 deadline. The plan is to be developed in
consultation with a broad range of representatives for public safety, persons with disabilities,
equipment and service providers and others.64 Congress required in the NET 911 Improvement
Act of 2008 that the National Plan “assess, collect, and analyze the experiences” of trial
deployments such as those conducted for NG9-1-1 by the Department of Transportation.65 The
various analyses of IP-based systems prepared as part of NG9-1-1 could provide the core of the
National Plan.
The National Plan is expected to describe positive steps to include 911 in the transition to IP-
enabled technologies and to provide recommendations where Congressional action could
facilitate the process.66 It is not clear what role, if any, a federal department or agency will have in
deploying the new technologies. The transition could occur through the combined efforts of states
with little participation by the federal government.
ȱȱ
A number of stakeholders are working to improve 911 capabilities and bring them to the next
generation of technologies. At the federal level, the Department of Transportation has been a
leader in defining actions that need to be taken. One of the NG9-1-1 reports prepared for DOT,
for example, discusses strategic options for funding, operations, standards and technology, and
governance and policy.67 The National Plan prepared by the ICO is required to provide specific
actions to be taken to bring about change. The plan’s publication could be the catalyst for a
renewed debate that may address issues raised by the National Plan and in this report. A debate
could prompt new legislation in support of the goals stated by Congress—such as equality of
access and the desire to use new technology to improve quality—that could provide the basis for
the next phase of federal leadership for 911. The cost of new systems and who should bear these
costs are also of concern to Congress.
ȱȱ
Investing in IP-enabled systems supports the twin goals of equality and quality. Only a digitized
system with seamless IP-based connectivity can fully support the needs of groups that are

62 P.L. 110-283, Sec. 102, (3) “(d) “(1); 122 STAT. 2623.
63 Ibid.
64 P.L. 110-283, Sec. 102, (3) “(d) “(3); 122 STAT. 2624.
65 P.L. 110-283, Sec. 102 (3) “(d) “(2) “(H) ; 122 STAT. 2623.
66 P.L. 110-283, Sec. 102 (3) “(d) “(2) “(F) and (G); 122 STAT. 2623.
67 U.S. Department of Transportation, Intelligent Transportation Systems, “Next Generation 9-1-1 System Initiative:
Preliminary Analysis of Cost, Value, and Risk, February2008 at http://www.its.dot.gov/ng911/pdf/
NG911_FINAL_PreliminaryCostValueRiskAnalysis_v2.0_021208.pdf.
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currently poorly served by 911 systems, including those with disabilities, residents and travelers
in rural areas, and workers and residents in high rise buildings. The current analog system, for
example, can only support text messages to 911 in work-around arrangements; yet, text
messaging is ideal for people with certain types of disabilities and is a more viable means of
communication than voice in times of high demand and widespread service outages, situations
that often follow a disaster. Better information on the source of a call, made possible by IP
technologies, would be a boon for rural and urban areas, where different technological problems
lead to the same consequence: inadequate location identification for incoming 911 calls.
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NHTSA has moved forward in assisting wireless E-911 as an extension of its Emergency Medical
Service (EMS) mission. In 2002, under the leadership of then-Secretary of Transportation
Norman Y. Mineta, DOT created the Wireless E9-1-1 Steering Council to foster cooperation and
dialog among key participants.68 In 2005, DOT announced plans to produce a national framework
and deployment plan for an NG9-1-1 system, to be developed over a three-year period. The new
initiative built on earlier wireless 911 projects within DOT. The NG9-1-1 program is administered
within the Research and Innovative Technology Administration (RITA), part of DOT’s Intelligent
Transportation Systems (ITS) program. Management of the program is shared between the ITS
Public Safety Program and NHTSA, with assistance from the consulting firm, Booz Allen
Hamilton.69
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DOT has published technical requirements and a concept of operations for NG9-1-1, has
implemented a strategic outreach plan, has begun work to develop and validate requirements for
the NG9-1-1 system, has defined the system architecture, and has developed a preliminary
transition plan.70 In the concept of operations, DOT stated
The primary goal of the NG9-1-1 System is to save lives, health, and property by improving
emergency services access and response in the United States. The state of the NG9-1-1
System also has a major effect on transportation security, mobility, and efficiency.71
The major features of the envisioned NG9-1-1 System that support this goal are described as
• Enable E-911 calls from any networked communications device.
• Enable geographic-independent call access, transfer, and backup among PSAPs
and between PSAPs and other authorized emergency organizations.
• Encourage a flexible, open, non-proprietary, and secure architecture to facilitate
the implementation of an interoperable network.

68 U.S. Department of Transportation, Wireless E9-1-1 Steering Council, Wireless E9-1-1 Priority Action Plan,
Foreword, at http://www.itsdocs.fhwa.dot.gov/JPODOCS/REPTS_TE/13884.html.
69 Background at http://www.its.dot.gov/NG911/.
70 U.S. Department of Transportation, Intelligent Transportation Systems, “Preliminary Transition Plan,” April 2008, at
http://www.its.dot.gov/ng911/pdf/ng911_preliminary_transition.pdf.
71 U.S. Department of Transportation, Intelligent Transportation Systems, “Next Generation 9-1-1 System Initiative:
Concept of Operations,” April 2007, page 8, at http://www.its.dot.gov/ng911/pdf/NG911ConOps_April07.pdf.
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• Foster increased coordination and partnerships within the public safety
community.
• Encourage standards coordination and interoperability in the United States and
internationally.
• Maximize emergency services capital, operating, and maintenance cost savings.72
ȱȱ
The long-term goals of the demonstration pilots are to define the system architecture and develop
a transition plan that considers responsibilities, costs, schedule, and benefits for deploying NG9-
1-1 nationwide. High-level functional components that have been successfully tested include
• Ability to send and receive voice, video, text, and data.
• Improvement to 911 access for deaf/hearing-impaired.
• Caller location identifications.
• Transmission of telematics data directly to the PSAP (referred to as Advanced
Automatic Crash Notification) like location, speed, vehicular rollover, and crash
velocity.
• 911 call routing and call transfer based on caller’s location.
• IP networking and security in an emergency communications environment.73
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Following completion of the demonstration pilots, data gathered during the proof of concept
testing will be analyzed and used to revise and complete the project’s preliminary system
architecture and transition plan.74 Reportedly, after the pilot programs end in November 2008, the
data will be shared with the ICO.75
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The costs to improve 911 through investments in infrastructure can be categorized by several
major and distinct functions of 911.76 For the purposes of this analysis, four cost centers and

72 Ibid.
73 U.S. Department of Transportation, Intelligent Transportation Systems, “Next Generation 9-1-1 System Initiative:
Proof of Concept Testing Report,” September 2008, page 7 at http://www.its.dot.gov/ng911/pdf/
NG911_POCTesTReport091708.pdf.
74 “US DOT Next Generation 9-1-1 Initiative—Proof of Concept Begins,” at http://www.its.dot.gov/ng911/docs/
ng911_initiative.htm.
75 “Five Cities Test High-Tech 911 System,” by Matthew Daneman, USA Today, July 9, 2008 at
http://www.usatoday.com/news/nation/2008-07-08-new-911_N.htm.
76 Health of the US 9-1-1 System, for example, describes three major element of the process: “call delivery;” “call
processing,” and “radio dispatch.” Page 36 et seq. Report at http://www.911alliance.org/
9IA_Health_of_US_911%20_2_.pdf.
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typical sources of funding are summarized below. These are: devices, local networks, call centers,
and interfaces with first responders.
ȱ
The cost of developing devices that comply with FCC requirements for caller information for 911
calls, especially location information, are borne by the communications service providers and
their suppliers, and by the consumers who subscribe to the services and buy these devices.
ȱ ȱ
To accommodate the needs of enhanced 911, local networks that provide routers and other
infrastructure invest in upgrades to their facilities. The costs for these investments to route calls
may be reimbursed through a state’s 911 fund or may be passed on to the PSAPs that purchase
access to the lines. Charges to PSAPs for communications services tend to rise as more features
are added by their local exchange. In some areas of the country there is little competitive pressure
to upgrade these links; the lack of access to an up-to-date infrastructure is one reason why some
areas of the country do not have enhanced 911 or even basic 911 services.
ȱȱ
To accommodate the information delivered through enhanced 911, PSAPs are required to invest
in call-processing equipment, computers, databases, and other equipment. The capital for these
investments may come from 911 or E-911 fees paid by subscribers into state 911 funds; the funds
are also used for operating costs. State grants and local fund-raising initiatives are other sources
for capital investment and operating costs. Federal grant programs target investments in PSAPs.77
ȱ ȱȱȱ
The final step in processing a 911 call is to relay information to emergency responders. After the
point of interface into the local first responder network, the effectiveness of the 911 system
depends on the capacity of the response network. The emergency communications networks for
public safety are also often constrained by the capabilities of old equipment as well as other
operational limitations, such as insufficient radio frequency spectrum and lack of communications
interoperability among different first responder groups. The upgrading of these networks are often
considered as separate from improvements in 911 systems although some states have used 911
funds to help pay for public safety communications networks. Congress and the Bush
Administration, as well as states and other entities, have typically addressed first responder
communications networks through a different set of policies and programs; several required
federal programs have yet to be fully realized.78

77 See Appendix, “Mechanisms to Improve Funding for PSAPs.”
78 Among the CRS reports addressing these issues is CRS Report RL33747, Emergency Communications Legislation:
Implications for the 110th Congress, by Linda K. Moore.
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Among the multiple factors and challenges of implementing NG9-1-1 are the costs of planning,
replacing, and upgrading systems, and maintaining and operating these new systems. A
preliminary analysis of cost, value, and risk prepared for DOT found that capital and operating
costs would be comparable for improving the existing 911 system and migrating to NG9-1-1
under several scenarios that projected these costs over a 20-year period.79 The model and
assumptions used for the preliminary evaluation of costs will be revised by DOT based upon the
results of the proof of concept pilot programs. A final projection of costs under differing scenarios
is to be completed by year end 2008.80
Several trends were identified as part of the value analysis process, primarily
• NG9-1-1 provides greater opportunities for cost savings and increased
operational efficiencies than the current 911 environment.
• NG9-1-1 has greater potential to meet the public’s expectations for accessibility
than the current 911 environment.
• NG9-1-1 has greater scalability and flexibility than the current 9-1-1
environment.
• NG9-1-1 has greater potential to increase public and responder safety through
inter-connectivity and interoperability than the current 911 environment.
The study therefore concludes that, to meet the needs of public safety and the general public’s
expectations, “the preferred solution is to migrate to the NG9-1-1 environment.”81
ȱ ȱ
The federal grant program administered by the ICO is scheduled to disburse $41,325,000 in
matching grants in 2009.82 While allowing for consideration of developing 911 services for
unserved communities, the proposed rules for the grant program would favor purchases of
hardware and software for enhanced 911 and IP-enabled systems, as well as training in
connection with these investments. The proposed allocation of funds would be by a formula that
gives equal weight to population and the number of miles of public road in each state. No state
that qualified for a grant would be allocated less than $500,000 ($250,000 for four territories
covered by the program). Nine states would be entitled to receive over $1,000,000 (California,
Florida, Georgia, Illinois, Michigan, New York, Ohio, Pennsylvania, and Texas). States receiving
funds must use them within three years, under the proposed rules. Because not all states will
apply (or will perhaps not be eligible) to receive grants, states would be encouraged to submit

79 U.S. Department of Transportation, Intelligent Transportation Systems, “Next Generation 9-1-1 System Initiative:
Preliminary Analysis of Cost, Value, and Risk,” February2008 at
http://www.its.dot.gov/ng911/pdf/NG911_FINAL_PreliminaryCostValueRiskAnalysis_v2.0_021208.pdf.
80 E-mail communication from Will Otero, Director, Legislative Affairs, National Highway Traffic Safety
Administration, October 21, 2008.
81 Ibid. Page ES-VII.
82 U.S. Department of Commerce News, “NHTSA and NTIA Unveil Grant program to help States Upgrade 9-1-1
Services,” October 3, 2008 at http://www.ntia.doc.gov/press/2008/E911grants_081003.pdf. October 3, 2008.
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supplemental requests for additional programs that might be funded.83 An analysis of all requests
for program funding, not just for the grants approved, could provide information about the scope
of investment needed to achieve a national 911 service.
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The Department of Homeland Security Appropriations Act, 2007 (P.L. 109-295) provided for
coordination of emergency communication grants,84 and for the formation of Regional
Emergency Communications Coordination (RECC) Working Groups.85 The requirement to
establish regional working groups responded in part to requests from the public safety community
to include the second tier of emergency workers in planning for interoperable communications.
Non-federal members of the RECC groups are to include first responders, state and local officials
and emergency managers, and 911 call center personnel.86 The Department of Homeland Security
(DHS) is the lead agency for the RECC plans and for other emergency communications planning
initiatives, notably the National Infrastructure Protection Plan, FEMA Disaster Emergency
Communications planning, and the National Emergency Communications Plan.87
ȱ¢ȱȱȱ
As part of the grants process for interoperable communications, Congress required the
preparation of a National Emergency Communications Plan (NECP).88 DHS issued the NECP in
July 2008.89 The primary purpose of the plan is to provide an overarching strategy for emergency
communications preparedness. To meet preparedness goals, the NECP provides guidelines and
deadlines for emergency managers at all levels of government. The improvement of 911 systems
and PSAP communications is among the plan’s objectives for Disaster Communications
Capabilities. Specifically, Initiative 7.2 of the NECP states that agencies with operational
responsibilities “should evaluate the readiness posture of communications centers (e.g., Public
Safety Answering Points)” for vulnerabilities. According to the plan, “System planning activities
should account for the availability of alternative and backup communications solutions and
redundant pathways (i.e., provided by different vendors) to support communications if primary
capabilities become unavailable.” A recommended 12-month milestone for this initiative is for
RECC Working Groups to work with state and local agencies to assess priority vulnerabilities that
could weaken critical mission response. Milestones to be achieved within 24 months that apply to
PSAPs and 911 systems include

8347CFR Part 400, E-911 Grant Program. Federal Register, October 3, 2008; link at http://www.ntia.doc.gov/
frnotices/2008/FR_E911grants_081003.pdf.
84 P.L. 109-295, Title VI, Sec. 671(b), “Title XVIII, “Sec. 1804; 120 STAT. 1438.
85 P.L. 109-295, Title VI, Sec. 671(b), “Title XVIII, “Sec. 1805; 120 STAT. 1439.
86 P.L. 109-295, Sec. 671(b), “Title XVIII, “Sec. 1805 “(b) “(1); 120 STAT. 1439.
87 DHS, National Emergency Communications Plan, July 2008, Exhibit A3-1: Key Emergency Communications Policy
and Planning Initiatives, page A-11. Plan at http://www.dhs.gov/xlibrary/assets/
national_emergency_communications_plan.pdf.
88 P.L. 109-295, Sec. 671 (b) “Title XVIII, “Sec. 1802; 120 STAT. 1435-1436.
89 DHS, National Emergency Communications Plan, July 2008, at http://www.dhs.gov/xlibrary/assets/
national_emergency_communications_plan.pdf.
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• Develop plans and procedures to enhance emergency 911 systems and PSAP
communications.
• Identify alternate and/or backup capabilities in emergency communications plans
defined by all federal, state, local, and tribal agencies.90
These goals for states to improve 911 systems are compatible with DOT’s efforts with 911 and
NG9-1-1; the DOT programs are referenced in the plan.91
The RECC Working Groups could play a part in forming future policies for the transition to NG9-
1-1. The working groups could provide another opportunity for federal leadership in assisting
911, especially in coordinating the transition to IP-enabled emergency communications.
ȱȱȱ¢ȱȱ¢ȱȱ
Cuts in expenditures on public services, including public safety, are underway or predicted in
states and counties across the country.92 Improvements in 911 systems and investments in new
radio systems and equipment for first responders could be among the expenditures that are
cancelled or postponed by states and counties.93 The questions of who will fund the transition to
NG9-1-1, and how—primary topics of debate—could become irrelevant, if there are no funds
available, or could be subsumed by a larger debate over federal policies for economic stimulus.
Alternatively, investment in public safety infrastructure could be part of an economic stimulus
plan. The transition to IP-enabled networks is occurring across the board as public safety moves
to next-generation technologies. Many infrastructure needs for public safety could be met with
policies to expand broadband access to consumers, small businesses, schools, and libraries. Better
access to information is as equally vital for public safety as it is for education, economic
development, and other economic and social goals.
The opening pages of this report identified some possible policy goals for Congress to consider in
supporting the transition to next-generation 911 technologies. As discussed throughout this report,
Congress has supported the goal of equality and quality for the existing 911 infrastructure and
seems to have signaled its intentions to maintain its support during the transition to more
advanced technologies.
ȱȱȬ£ȱȱȬşŗŗȱȱȱ
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For the nation to meet some of the suggested policy goals, restated below, may require integrating
goals for 911 with other policy goals that are broader in scope, such as rebuilding infrastructure or
assuring a modern radio network for public safety.94 Re-authorization of the E-911

90 Ibid., Objective 7: Disaster Communications Capabilities, Initiative 7.2, page 38.
91 Ibid., Exhibit A3-2: Federal Tactical and Emergency Communications Systems and Services, pages A12-A13.
92 “Pain of bulging budget gaps,” Financial Times, December 12, 2008.
93According to the Financial Times, California recently raised $5 billion in a bond to cover short-term spending
obligations, including paying firefighters. “California faces prospect of running out of cash,” December 12, 2008.
94 Ongoing efforts to create a new network with national coverage and interoperability are discussed in CRS Report
(continued...)
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Implementation Coordination Office, with the requirement to study and report to Congress on
additional options for the transition to IP-enabled emergency communications, could be one path
to bring 911 policies in line with other policies, such as upgrading communications infrastructure
and improving federal assistance for emergency response and recovery after major disasters.
Extending the authorization of the ICO might also be beneficial for states that want to apply for
matching grants under the program being established for 911. Although under the proposed rules
for the grant program the states have until 2012 to use the funds granted to them,95 they have only
a brief period to submit their requests.96 This timetable is to ensure that the grant process is
completed before the ICO’s authorization ends.97
A newly empowered ICO could be charged to address immediately the important policy
considerations that may otherwise be addressed separately, and over time, after the National Plan
for transition to IP-enabled emergency communications is submitted. It is important to establish
an understanding within Congress of what is expected of 911 services and the infrastructure
needed to support those services. A sequence of goals in support of 911 systems might follow
along these lines.
¢ȱ¢ȱ ȱ
Consider 911 call completion an essential service, establishing goals for improvements in quality
and accessibility that are consistent with goals set for public safety and homeland security. Steps
to achieve these goals could include
• Establishing national guidelines or requirements for minimum levels of 911
service.
• Establishing a program to assure that the quality of 911 services improves
steadily, nationwide.
ȱ¢ȱ Ǳȱ£ȱ
Establish an enduring agreement for cooperation and mutual support between federal, state,
county, local, and tribal governments to support public safety and emergency communications
policy goals, including 911. Steps to achieve this could include
• Identifying the federal role in implementing national policies for emergency
communications without eroding state and local authority.
• Providing funding solutions.
• Defining the role of the Department of Homeland Security, especially the
Regional Emergency Communications Coordination Working Groups that it

(...continued)
RL34054, Public-Private Partnership for a Public Safety Network: Governance and Policy, by Linda K. Moore.
95 47 CFR Part 400, E-911 Grant Program, §400.10. Federal Register, October 3, 2008.
96 Ibid. §400. 4 (b). 60 days from the time rules are finalized and published in the Federal Register.
97 Update on program activities provided in a telephone discussion with Kathy Smith, Chief Counsel for the NTIA,
June 26, 2008.
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supports, in guiding policies to sustain and improve 911 as part of the Emergency
Communications Plan.
• Defining the role of the Chief Technology Officer (CTO), a new position in the
White House. The CTO is expected to be given the responsibility of improving
public safety communications planning and policy, duties already assigned by
Congress to DHA and other agencies.
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Identify needed improvements in communications infrastructure, including wireless networks, to
support IP-enabled emergency communications on a national basis. Steps to achieve this could
include
• Addressing emergency communications needs and goals with a policy statement
that recognizes the convergence of technologies, especially IP-based networks
and standards, that will place first responder networks, 911 systems, and
emergency alert systems on common, interoperable platforms.
• Reviewing the federal regulatory role in promoting competition in the provision
of network services to PSAPs.98
• Designating spectrum to provide connectivity to PSAPS, for example by using
wireless technologies such as microwave transmission in place of fiber-optic
cables.
• Addressing the quality of interfaces with other emergency communications
networks, especially the radio links to first responders and their spectrum needs.
The information that is expected from the National Plan is important to Congressional
consideration of any of the above-suggested goals and other goals that may be suggested. A first
step for the 111th Congress, therefore, may be to exercise the necessary oversight to see that the
plan is completed and delivered, as required by the NET 911 Improvement Act of 2008, before
the end of April 2009. Congress could also consider the creation of other means to coordinate
Congressional policy and monitor progress toward the inter-related goals of creating an IP-
enabled emergency communications network, improving first responder communications, and
upgrading the emergency alert system to digital mode.

98 The wireline circuits that complete the connection to the PSAPs are usually owned and operated by either an
Incumbent Local Exchange Carrier (ILEC) or a Competitive Local Exchange Carrier (CLEC), operating under different
regulatory requirements and protections. The Wireline Competition Bureau of the FCC oversees federal regulation of
ILECs and CLECs. State regulations are also usually in place, typically administered by the state utility commission.
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This section provides further detail and documentation about 911 requirements enacted by
Congress and related administrative activities.
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Many of the FCC’s regulatory efforts have supported this principle by requiring that different
providers of voice communications services be able to provide 911 facilities with basic
information about a caller, specifically call-back number (Automatic Number Information, ANI)
and location (Automatic Location Identification, ALI).99
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The 911 Act assured that wireless carriers would have similar obligations and protections in
transmitting 911 calls as the wireline common carriers.100 The NET 911 Improvement Act of 2008
extended these obligations and protections to include Voice Over Internet Protocol (VOIP).101 The
Federal Communications Commission (FCC) is responsible for promulgating and enforcing
regulations to assure that cell phone and VOIP calls, as well as those from wireline phones,
convey required information to the appropriate Public Safety Answering Point (PSAP). Providing
position information that locates cell phone or VOIP callers in a manner comparable to wireline
information is one of the challenges for parity among devices.
Another challenge is presented by connections to third-party service providers. For example,
telematics systems installed in cars, such as OnStar; direct emergency calls automatically to a
customer service operator who then places the call to 911, usually identifying the appropriate call
center from a database. Video Relay Service for the hearing impaired is another example of an
intermediary placing the call to a PSAP. Access to PSAP contact information for third-party
service providers continues to be an issue of concern to companies that provide services that
include contacting 911 for assistance. To address this concern, the National Emergency Number
Association (NENA) maintains a registry of PSAP information that it makes available to
validated call centers as well as PSAPs.102 The NET 911 Improvement Act of 2008 specifically
authorized, but did not require, the FCC to compile a list of contact information of public safety
answering points and make the information available where releasing it would benefit public
safety.103 The NET 911 Improvement Act of 2008 also extended parity of protection to duly
authorized emergency communications service providers that voluntarily offer these services.104

99 Also discussed in earlier section, “The 911 Act and Federal Communications Commission Regulations.”
100 P.L. 106-81, Secs. 3, 4, and 5. 113 STAT. 1286 et seq.
101 P.L. 110-283, Sec. 101, “Sec. 6 “(a) and “(b) and Sec. 201; 122 STAT. 2620 and 122 STAT. 2624.
102 North American 9-1-1 Resources Database, information at http://www.nena.org/pages/ContentList.asp?CTID=40..
103 P.L. 110-283, Sec. 101, “Sec. 6 “(g); 122 STAT. 2622.
104 P.L. 110-283, Sec. 201 (b) “(9) “(B); 122 STAT. 2625.
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The location of a caller often determines the level of response from a PSAP. The likelihood of a
911 call being completed with accurate information depends on two essential components: the
capacity of the network and systems to capture and deliver the needed information and the
capability of the PSAP to receive it. Providing location information in rural areas, for example,
can be difficult for wireless carriers, partly because of inadequate infrastructure.105 Reflecting
concerns that some carriers would stop serving remote areas rather than invest in improving
location identification capabilities, the ENHANCE 911 Act of 2004 directed the FCC to grant
waivers to Tier III wireless carriers106 in situations where strict enforcement would decrease
access to emergency services.107
The ENHANCE 911 Act of 2004 also required the FCC to study the situation of Tier III wireless
carriers regarding the waiver process and to provide information on effective technologies for
implementing Phase II of W-E911.108 The FCC submitted a detailed report in April 2005 but made
no recommendations regarding technology.109
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In addition to problems in rural areas, noted above, high-density urban areas also have location
problems, such as when a 911 call is made from inside a high-rise building. Even if wireless E-
911 is in place at the appropriate PSAP, location identification can provide a street address but not
a floor level. Location information is readily available for wireline phone subscribers, as most
telephone service providers have identifiable addresses stored in their databases. (Many rural
areas have invested in converting generic rural addresses, such as rural routes or post office
boxes, into house-specific coordinates for 911 location information.)
The Association of Public-Safety Communications Officials International, Inc. (APCO)
conducted an independent test of the accuracy of location information received by PSAPs that
indicated many failings in the provision of location information from wireless calls.110 Partially in
response to the APCO study, the FCC opened a new proceeding and in November 2007 proposed
rules for carriers to provide more accurate location information to PSAPs.111 Verizon, AT&T, and

105 Problems have included the switch from analog to digital technology for cellular services (digital technology
provides significantly better location-finding capability but analog transmissions have a wider reach), the difficulty of
installing a sufficient number of cell towers to provide “triangulation” for location technologies; and the predominance
of cell towers placed along major highways (sometimes referred to as a “string of pearls”), also a complication for
proper triangulation.
106 For enforcement purposes, the FCC divided wireless carriers into three tiers: Tier III (small); Tier II (mid-sized);
and Tier I (the largest carriers—Verizon, Cingular, T-Mobile, and Sprint Nextel).
107 P.L. 108-494, Section 107 (a); 118 STAT. 3991.
108 P.L. 108-494, Section 106; 118 STAT. 3390.
109 Amended report submitted April 1, 2005. The FCC concluded that technologies currently in use were all suitable
and that the choice depended on a variety of factors. “FCC Amended Report to Congress on the Deployment of E9-1-1
Phase II Services by Tier III Service Providers” at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-
257964A1.pdf.
110 “APCO Wireless Accuracy Testing Discovers Critical Information to the 9-1-1 Caller,” http://www.apcointl.org/
news/2006/20060822APCOWirelessAccuracyTestDiscovery.html Press release, August 22, 2006. The final report on
findings was released in April 2007, http://www.locatemodelcities.org/documents/LOCATE_Final_Report.pdf.
111 FCC News, “FCC Clarifies Geographic Area Over Which Wireless Carriers Must Meet Enhanced 911 Location
(continued...)
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other carriers and industry groups questioned whether the FCC’s ruling was technically feasible
and recommended a 911 working group to develop and agree upon standards for location
accuracy and other features of 911.112 The FCC withdrew the contested rules and in September
2008 sought comments on new service rules for location accuracy.113
The NET 911 Improvement Act of 2008 directed the FCC to work with PSAPs, the industry, and
the E-911 Implementation Coordination Office to improve standards and best practices for a
number of goals related to location identification. The NET 911 Improvement Act of 2008 also
requires that the National Plan identify location technologies for nomadic devices and for office
buildings and multi-dwelling units.114
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To meet anticipated new requirements for location information at the PSAP level, wireless
carriers will need to improve the technology they use. PSAPs must also invest in technology in
order to receive more detailed information. Guidance and assistance for these tasks are provided
primarily at the state and local level. NENA and APCO are active in providing frameworks for
decision-making and technical reports.115 The Seventh National Reliability and Interoperability
Council (NRIC), a federal advisory committee to the FCC, provided best practices and other
analyses for PSAPs to improve 911 operations.116 It also urged the development of a common
platform that would link 911 to an interoperable communications network based on Internet
technologies.117 The FCC’s February 2008 summit for 911 circulated a list of best practices for
PSAPs.118 To address PSAP needs, the National Plan required by the NET 911 Improvement Act
of 2008 must contain “specific mechanisms for ensuring the IP-enabled emergency network is
available in every community.... ”119

(...continued)
Accuracy Requirements,” September 11, 2007. FCC, Report and Order, adopted September 11, 2007, released
November 20, 2007,CC Docket No. 94-102; http://hraunfoss.fcc.gov/edocs_public/Query.do?mode=advance&rpt=full
for all document links.
112 See comments at FCC Electronic Comment Filing System from, for example, CTIA, AT&T (various divisions),
Verizon Wireless, Inc., and Sprint Nextel Corporation. Docket No. 07-114. This letter filed by CTIA on September 6,
2007 is one example: http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519722596.
113 FCC Public Notice, “Comment Sought on Proposals Regarding Service Rules for Wireless Enhanced 911Phase II
Location Information and Accuracy,” September 22, 2008, DA 08-2129, Docket No. 07-114.
114P.L. 110-283, Sec. 102, (3) “(d) “(2) “(D); 122 STAT. 2623.
115 NENA: information on courses, standards documents, and other resources for 9-1-1 Professionals at
http://www.nena.org/; APCO: Communications Center and 9-1-1 Services at http://www.apcointl.org/new/
commcenter911/.
116 NRIC VII, Focus Group I, “Enhanced 911,” subcommittee reports published in 2004-2005, at http://nric.org/fg/
index.html.
117 NRIC VII, Focus Group 1D, “Communications Issues for Emergency Communications Beyond 911; Report #1—
Properties and network architectures that communications between PSAPs and emergency services personnel must
meet in the near future,” December 6, 2004, pp. 12, 26-27, at http://nric.org/meetings/docs/meeting_20041206/
FG1D%20Final%20Report.pdf.
118 911 Call Center Operations and Next Generation Technologies Summit, February 6, 2008; recommendations at
http://www.fcc.gov/pshs/summits/911/improving911callcenterops2.html.
119 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(C); 122 STAT. 2623.
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The NET 911 Improvement Act of 2008 has required the National Plan to identify solutions for
providing 911and access to those with disabilities.120 The FCC currently enforces Title IV of the
Americans with Disabilities Act (P.L. 101-336) for access to telecommunications services.121
Requirements for wireless carriers to accommodate TTY calls to 911 have been part of the FCC
regulations since rules were first promulgated in 1996.122 The FCC is endeavoring to improve 911
support provided through Internet-based forms of the Telecommunications Relay Service that
allow persons with hearing and speech disabilities to communicate with hearing users of
telephone services.123
Legislation proposed in the 110th Congress by Representative Edward J. Markey would, among
other provisions, “ensure equal access to emergency services by individuals with disabilities” by
requiring the provision of “seamless” real-time text communications.124
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The ENHANCE 911 Act of 2004 provided a mechanism for funding 911 with a program of
matching grants.125 Authorizations of up to $250 million annually for program activities and
grants were established for fiscal years 2005 through 2009, with authority for authorizations set to
expire on October 1, 2009. Despite the authorization, no appropriations were made, although
some funding was provided through the Digital Transition and Public Safety Fund, created by the
Deficit Reduction Act of 2005 (P.L. 109-171). The NTIA is responsible for administering
distributions from the fund, as designated by Congress in the act. Up to $43.5 million was
designated specifically for 911, payable from the proceeds of spectrum auctions that took place in
early 2008.126 The Implementing Recommendations of the 9/11 Commission Act of 2007
authorized the National Telecommunications and Information Administration (NTIA) to borrow
against the $43.5 million from spectrum auction proceeds127 and included an amendment that
favors Public Safety Answering Points not capable of receiving 911 calls.128 There are 91 counties
in the United States where emergency calls are handled without the benefit of any 911
technology.129 The NET 911 Improvement Act of 2008 further amended the guidelines for grant
eligibility by adding “migration to an IP-enabled emergency network” as a qualifying program
for grant funds.130 The NTIA, working with the National Highway Traffic Safety Administration

120 P.L. 110-283, Sec. 102 (3) “(d) “(2) “(I); 122 STAT. 2624.
121 More information at http://www.fcc.gov/cgb/dro/.
122 TTY refers to a text telephone; another common term is TDD, for Telecommunications Device for the Deaf.
123 FCC, Report and Order and Further Notice of Proposed Rulemaking, WC Docket No. 05-196, adopted June 11,
2008. At http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-08-151A1.pdf.
124 Twenty-first Century Communications and Video Accessibility Act of 2008, H.R. 6320, Sec. 106.
125 P.L. 108-494, Sec. 104, “Sec. 158 “(b); 118 STAT. 3987.
126 P.L. 109-171, Sec. 3011; 120 STAT. 27
127 P.L. 110-53, Sec. 2302; 121 STAT. 543.
128 P.L. 110-53, Sec. 2303; 121 STAT. 543.
129 Provided by NENA, telephone discussion with Patrick Halley on October 21, 2008.
130 P.L. 110-283, Sec. 102 (1); 122 STAT. 2623.
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(NHTSA), has issued proposed rules for the grant process. The program will be administered by
the NHTSA.131 The funds will be awarded in FY2009.132
In addition to establishing a grants program to help PSAPs install 911 systems, the ENHANCE
911 Act of 2004 provided a mechanism to penalize states and other jurisdictions that diverted fees
collected for 911 to other purposes.133 This provision was in response to reports of abuses
documented by CTIA - The Wireless Association in 2003;134 later abuses have also been
documented.135 To discourage this practice, the ENHANCE 911 Act of 2004 structured its
matching grants program to refuse federal grants to jurisdictions where funds collected for 911
were used for other purposes.136 As required in the act,137 the Government Accountability Office
prepared a report about state and local 911 systems that included an analysis of surcharges and
their uses.138
The NET 911 Improvement Act of 2008 established an annual requirement for the FCC to prepare
a survey of the collection and disbursement of fees collected for 911 and by states and political
subdivisions and to report if fees are diverted.139 The purpose of the reporting requirement is to
“ensure efficiency, transparency, and accountability.” The act also specifically allows states to
collect a fee on VOIP services with the proviso that the fees must be used for 911 or E-911.140
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The Food, Conservation, and Energy Act of 2008 (P.L. 110-234), referred to as the 2008 Farm
Bill, included language that can provide loans to improve 911 and other emergency
communications capabilities in rural areas. The provision amends the Rural Electrification Act
lending authority141 to include
“facilities and equipment to expand or improve in rural areas—
“(1) 911 access;

131 Published in the Federal Register October 3, 2008, link at http://www.ntia.doc.gov/frnotices/2008/
FR_E911grants_081003.pdf.
132 U.S. Department of Commerce News, “NHTSA and NTIA Unveil Grant program to help States Upgrade 9-1-1
Services,” October 3, 2008 at http://www.ntia.doc.gov/press/2008/E911grants_081003.pdf. October 3, 2008.
133 P.L. 108-494, Sec. 104, “Sec. 158 “(c); 118 STAT. 3988.
134 The CTIA maintains a database of expenditures from 911 and E-911 funds, available upon request through CRS.
135 For example, as reported in Health of the US 9-1-1 System, page 67. See also “How the State Abused Your Monthly
Cell Phone Tax,” September 21, 2008, Central New York News, syracuse.com at “Mechanisms to Improve Funding for
PSAPs,” at http://www.syracuse.com/news/index.ssf/2008/09/the_cell_phone_bill_says.html. Viewed October 3, 2008.
136 P.L. 108-494, Sec. 104 “Sec. 158; 118 STAT. 3987-3990.
137 P.L. 108-494, Sec. 105; 118 STAT. 3990.
138 GAO, States’ Collection and Use of Funds for Wireless Enhanced 911 Services, March 2006, GAO-06-338. A
second report carried further documentation, Summary of State Wireless E911 Funds, March 2006, GAO-06-400SP.
139 P.L. 110-283, Sec. 101, “Sec. 6, “(f), “(2); 122 STAT. 2622.
140 P.L. 110-283, Sec. 101, “Sec. 6, “(f), “(1); 122 STAT. 2622.
141 Interim rule with request for comment in effect January 16, 2009. See Rural Development Guaranteed Loans,
Federal Register, December 17, 2008, link at http://frwebgate6.access.gpo.gov/cgi-bin/PDFgate.cgi?WAISdocID=
863218460594+0+2+0&WAISaction=retrieve.
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“(2) integrated interoperable emergency communications, including multiuse networks that
provide commercial or transportation information services in addition to emergency
communications services;
“(3) homeland security communications;
“(4) transportation safety communications; or
“(5) location technologies used outside an urbanized area.”142
The bill allows government-collected fees such as state and local fees for 911 to be used as surety
against loans.143 It also permits loans to companies that will provide communications equipment,
if local governments with jurisdiction are not allowed to acquire the debt.144
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A large share of the costs for implementing 911 services is covered by the telecommunications
industry and by state and/or local taxes or surcharges assessed on wireline and wireless telephone
bills.145 Most states have some form of 911 or E-911 fund that receives revenue from telephone
bill surcharges and distributes it to various jurisdictions; some states also compensate telephone
companies for 911-related expenses. Another source of funding, at the local or county level, is an
increase in property taxes with the additional monies going to PSAPs. Call center operators also
hold fund-raisers like fish fries and bake sales.
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Language in support of a leadership role by a federal agency to guide 911 policy appears in each
of the major bills that Congress has passed. The ENHANCE 911 Act of 2004, for example, stated
Enhanced 911 is a high national priority, and it requires Federal leadership, working in
cooperation with state and local governments and with the numerous organizations dedicated
to delivering emergency communications services.146
The ENHANCE 911 Act of 2004 recognized the role of the U.S. Department of Transportation
(DOT) in providing sustained support of 911 by making it a co-administrator of the E-911
Implementation Coordination Office (ICO). The FCC has also played a visible role in supporting
911, much of it through regulation.
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Charged in the 911 Act of 1999 to take positive steps to address the implementation of 911
services, the FCC has primarily played the role of regulator of wireless communications service

142 P.L. 110-234, Sec. 6107 “Sec. 315 “(a); 122 STAT. 1198.
143 P.L. 110-234, Sec. 6107 “Sec. 315 “(b); 122 STAT. 1198.
144 P.L. 110-234, Sec. 6107 “Sec. 315 “(c); 122 STAT. 1198.
145 A summary of surcharges is at http://www.nena.org/media/files/9-1-1UserFees4_1.pdf.
146 P.L. 108-494, Sec. 102 (4) 118 STAT. 3986.
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providers, promulgating and enforcing regulations to provide ANI/ALI information. Beginning in
2003, the FCC has held occasional public forums to discuss 911 deployment and possible
actions.147
After the establishment of the Public Safety and Homeland Security Bureau in 2006, the FCC
took action on another requirement of the 911 Act: to “encourage each State to develop and
implement coordinated statewide deployment plans, through an entity designated by the governor,
and to include representatives of the foregoing organizations and entities in development and
implementation of such plans.”148 It has contacted each state governor and requested information
about points of contact for emergency communications. As these are provided, the FCC posts
them on a website established for that purpose.149
The 2007 appropriations bill for the Department of Homeland Security included a requirement
that the FCC submit a report to Congress on the capacity, nationwide, for rerouting 911 calls
when call centers are disabled by disaster. The law specified that the report would cover the
“status of efforts of State, local, and tribal governments to develop plans for rerouting 911 and
E911 services in the event that public safety answering points are disabled during natural
disasters, acts of terrorism, and other man-made disasters.”150
In the required report, the FCC focused on administrative mechanisms not system capacities,
indicating that most states had some form of backup plan. The report did not explore the
limitations of existing technology nor consider possible changes to improve backup capacity. The
report was submitted to Congress in September 2007 but has not been made public.
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The keystone of the ENHANCE 911 Act of 2004 was the mandate to establish a program “to
facilitate coordination and communications between Federal, State, and local emergency
communications systems, emergency communications personnel, public safety organizations,
telecommunications carriers, and telecommunications equipment manufacturers and vendors
involved in the implementation of E-911 services.”151 The act designated the director of the
National Telecommunications and Information Administration (NTIA) and the Administrator of
the National Highway Traffic Safety Administration (NHTSA) to direct the program as co-
administrators of an E-911 Implementation Coordination Office. The two offices were to develop
a management plan to be submitted to Congress.152 Once the office was established, the co-
administrators were required to report to Congress annually on activities “to improve
coordination and communication with respect to the implementation of E-911 services.”153 Absent
funding from specifically-designated appropriations, the program as required by Congress was
not established at the time. NHTSA, in conjunction with DOT’s Intelligent Transportation

147 Agenda for the first meeting of the Wireless E911 Coordination Initiative, April 23, 2003 at http://hraunfoss.fcc.gov/
edocs_public/attachmatch/DA-03-1172A1.pdf. Subsequent public meetings were held on October 29-30, 2003;
February 12, 2004; April 27-28, 2004; November 15, 2006 (on access for the disabled); and February 6, 2008.
148 P.L. 106-81, Sec. 3 (b); 113 STAT. 3.
149 At http://www.fcc.gov/pshs/services/911-services/state.html.
150 P.L. 109-295, Sec. 674; 120 STAT. 144.
151 P.L. 108-494, Sec. 104, “Sec. 158, “(a) “(1) “(A); 118 STAT. 3987.
152 P.L. 108-494, Sec. 104, “Sec. 158, “(a) “(2);118 STAT. 3987.
153P.L. 108-494, Sec. 104, “Sec. 158, “(a) “(4);118 STAT. 3987.
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Systems program, moved forward with the Next Generation 911 Initiative. Once funding became
available as part of the Deficit Reduction Act, the NTIA moved to sign a memorandum with DOT
and prepare regulations for the grants programs for public comment. The NTIA has stated that it
expects the grants program activities will be concluded before the authorization for ICO expires
in 2009.154 The NET 911 Improvement Act of 2008 gave ICO the new responsibility of creating a
National Plan for the migration to IP-enabled emergency communications network to support 911
and other citizen-activated calls. Citizen-activated calls for help currently go to 911, to 311, to
211, and to other call centers in both the public and private sector.155 Because the ICO is charged
primarily with improving 911 service, it could limit the scope of the National Plan to 911 calls.
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The NET 911 Improvement Act of 2008 has required that ICO “shall develop and report to
Congress on a national plan for migrating to a national IP-enabled emergency network capable of
receiving and responding to all citizen-activated emergency communications and improving
information-sharing among all emergency response entities.”156 The plan is to be delivered no
more than 270 days after enactment of the bill,157 which would suggest a late-April 2009
deadline. The plan is to be developed in consultation with a broad range of representatives for
public safety, person with disabilities, equipment and service providers and others.158 Although
citizen-activated calls is a broader category than 911, including, for example, calls placed to 211
for assistance after a major disaster, the ICO could limit the scope of the National Plan to 911
calls, since that is the focus of its Congressional mandate. A number of requirements for the plan
have been referenced in the preceding sections. They are recapped below, organized by the policy
goal that each provision would support.
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• Provide mechanisms to ensure that the IP-enabled emergency network is
available in every community and is coordinated at the local, state, and regional
level.159
• Identify location technology for nomadic devices and for office buildings and
multi-unit dwellings.160
• Identify solutions for those with disabilities, steps to be taken, and a timeline for
action.161

154 Update on program activities provided in a telephone discussion with Kathy Smith, Chief Counsel for the NTIA,
June 26, 2008.
155 An overview of 211 is provided in Appendix B.
156 P.L. 110-283, Sec. 102, (3) “(d) “(1); 122 STAT. 2623.
157 Ibid.
158 P.L. 110-283, Sec. 102, (3) “(d) “(3); 122 STAT.2624.
159 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(C); 122 STAT. 2623.
160 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(D); 122 STAT. 2623.
161 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(I); 122 STAT. 2624.
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• Analyze efforts to provide automatic location information and provide
recommendations for necessary regulatory or legislative changes.162
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• Identify barriers that must be overcome and funding mechanisms to address
barriers.163
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• Outline the potential benefits of migrating to a national IP-enabled emergency
network for citizen-activated calls.164
• Include a proposed timetable, an outline of costs, and potential savings for the
transition to IP technologies.165
• Provide specific legislative language, if necessary, for achieving the plan.166
• Provide recommendations on any legislative changes, including updating
definitions, necessary to facilitate a national IP-enabled network.167
• Assess, collect, and analyze information from trial deployments of IP-enabled
emergency networks.168
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Although there are several requests for recommendations for legislation, if necessary, there is no
language in the NET 911 Improvement Act of 2008 to indicate what entity, federal or otherwise,
will have the responsibility of responding to Congress after the National Plan is submitted.

162 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(J); 122 STAT. 2624.
163 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(B); 122 STAT. 2623.
164 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(A); 122 STAT. 2623.
165 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(E); 122 STAT. 2623.
166 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(F); 122 STAT. 2623.
167 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(G); 122 STAT. 2623.
168 P.L. 110-283, Sec. 102, (3) “(d) “(2) “(H); 122 STAT. 2623.
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The term citizen-activated emergency call refers generally to calls placed by individuals seeking
assistance in an emergency. These calls are differentiated from alerts sent by authorities to warn
communities of potential danger or to provide instructions after a disaster. Citizen-activated calls
for help currently go to 911, to 311, to 211, and to other call centers in both the public and private
sector. The 311 code was created by the Federal Communications Commission (FCC) in 1997 to
take non-emergency police calls as a means to reduce congestion on 911 lines.169 The 211 dialing
code is reserved by the FCC on a provisional basis as a universal number for community
information and referral.170 The 211 call centers support a variety of social service hot lines—
including assistance in foreign-languages—and can also be used to provide information and
guidance in emergency situations.171 A large part of the U.S. population has access to 211 call
services but no state has statewide service.172 Many cities have adopted shared-service
communications hubs handling 211 and 311 calls. Service levels and response times for all types
of citizen-activated calls would benefit from a transition to IP-enabled networks and in many
cases could share infrastructure with 911 networks
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Call centers are identified as a pivotal link in an end-to-end network of emergency
communications, information, response, and post-incident care. A report by the Wireless
Emergency Response Team (WERT) discusses the valuable help provided to victims of the
September 11, 2001 World Trade Center attack through call center services donated by
BellSouth.173 Over 400 hotlines were established in New York City after 9/11, however, creating a
confusing network for victims and volunteers.174
After Hurricane Katrina, call centers, including 211 call centers, were used to help locate
displaced victims and direct them to shelters and social services.175 A post-hurricane evaluation
by the Federal Emergency Management Agency (FEMA) after the 2005 season recommended
that states establish 211 systems as part of their plans for response and recovery.176
A study of the role of 211 call centers during the Florida hurricane season of 2004177 documented
a number of ways that the call centers were of assistance:

169 FCC News, “FCC Creates New 311 Code for Non-Emergency Police Calls ... ,” Report CC 97-7, February 19, 1997
at http://ftp.fcc.gov/cgb/dro/311news.html.
170 More information is on the FCC website at Consumer and Governmental Affairs Bureau, Consumer Alerts and Fact
Sheets, http://www.fcc.gov/cgb/consumerfacts/211.html.
171 More information on 211, including links to cost-benefit studies, is available at http://www.211us.org.
172 In November 2008, the percentage was 78%. Thirty-one states covered more than 90% of the population. Statistics
and U.S. map showing coverage is available at http://www.211us.org/status.htm.
173 Wireless Emergency Response Team (WERT), “Final Report for the September 11, 2001 New York City World
Trade Center Terrorist Attack,” October 2001, Section 3.14, page 18, at
http://www.nric.org/meetings/docs/wert_final_report.pdf.
174 Cited as Findings in S. 211, Sec. 2, (9) and H.R. 211, Sec. 2, (9).
175 Findings, H.R. 211, Sec. 2 (10).
176 FEMA, FEMA Recovery Division 2005 Hurricane Season After Action Report, June 26, 2006.
177 Trial by Wind and Water: How 2-1-1 Played a Vital Role During the 2004 Florida Hurricanes, United Way of
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• expanded the capacity of Emergency Operations Centers by providing trained
information and referral specialists;
• offered additional access points for public information;
• managed information about the availability of services;
• identified unmet and emerging needs;
• helped prioritize and direct resources;
• provided reassurance and crisis support;
• helped mobilize and manage volunteers and donations;
• served as intake points for government agencies and non-profit organizations;
• offered sustained support for long-term recovery efforts.178
In addition to disaster recovery efforts, 211 call centers respond to a wide range of social service
needs for information and counseling, such as parent support, suicide prevention, health
information, traveler’s aid, tracking and helping welfare clients, and housing assistance.179
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In 2008, the Department of Homeland Security (DHS) awarded a grant to Texas A&M Research
Foundation to study 211 calls, initiating what DHS calls the Public Needs Project. The objective
of the research is to provide information for state call centers to develop systematic approaches to
responding to calls after major disasters. The study will analyze calls for assistance made to the
26 211 call centers in Texas during a four-month period before, during, and after Hurricanes
Katrina and Rita. Researchers will correlate these findings with demographic data to evaluate
where needs were the greatest. The study’s conclusions could provide the basis for incorporating
211 call centers into federal planning for emergency response and funding for infrastructure. The
initial conclusions from the study could be available by year-end 2009. 180 The WERT report
issued after the September 11 attacks urged that national planning for emergency preparedness
and response include the mobilization of private-sector call centers to field calls for information
and assistance for non-life-threatening needs.181
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Legislation introduced in the 111th Congress includes two bills covering 211 call centers: S. 211
(Senator Clinton) and H.R. 211 (Representative Eshoo). Both would authorize funds and require
improvements in the capacity of 211 help lines operated by nonprofit call centers. A question for

(...continued)
America at http://www.211us.org/documents/TrialbyWindandWater.pdf.
178 Ibid. Executive Summary.
179 “50 Ways 2-1-1 Works,” complied by United Way of Pennsylvania, at
http://www.211us.org/documents/50ways.pdf.
180 “DHS Seeks Template for Responding to Emergency Calls,” by Brian Robinson, FCW.com, August 26, 2008.
181 “Final Report for the September 11, 2001 New York City World Trade Center Terrorist Attack,” op. cit., Section 1,
Recommendation PCC-2, page 9 and Section 6, Public Call Center, page 40 et seq.
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the 111th Congress might be whether federal funding for 211 call centers meshes with other goals
that are expected to have priority, such as job creation and investment in infrastructure.
Recommendations from the DHS study on 211 might advocate additional funding for 211
services because of their role in emergency response. This could provide a different viewpoint for
Congress to evaluate funding programs.

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Linda K. Moore

Analyst in Telecommunications Policy
lmoore@crs.loc.gov, 7-5853

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